The Department of Health Services is seeking federal approval on a waiver to drug screen childless adults. Under the proposal, DHS would also be allowed to impose premiums on that population and cap eligibility for the program for those not working or in work training programs at four years.

If a member hits that cap or doesn't pay premiums, they'd be ineligible for Medicaid for six months. The state provides ways for members to regain their benefits sooner if they complete certain requirements. A federal public comment period on the waiver ends Saturday.

UnitedHealthcare Community Plan of Wisconsin, which serves 166,000 Medicaid members in Wisconsin, warned that limiting benefits for a six-month period could "negatively impact continuity of care" for childless adults, "driving up overall healthcare costs for the population."

Interruptions in Medicaid coverage can lead to greater emergency department use, they warned, as well as increases in hospitalizations for conditions that can be managed through other means.

"While Wisconsin's coverage suspension is limited to six months, research has shown that even short-term losses of coverage can have significant impact," said Ellen Sexton, UnitedHealthcare Community Plan of Wisconsin CEO.

The insurer recommended that Wisconsin use a tiered benefit system, like Indiana pursued. Medicaid recipients in Indiana that meet specific requirements have access to a full benefits package while those that don't lose access and receive a "skinnier" package of benefits. The state could also consider a hardship exemption for members that can't meet all the requirements to maintain coverage.

A spokesman for UnitedHealthcare declined to comment on the testimony or whether the organization still has the same concerns about the proposal. The insurer has other recommendations in the letter, relating to its role under the provision and the proposed healthy behavior incentives.

In its revised waiver application submitted to the federal government, DHS noted that exemptions to their proposal mean a small percentage of members would be affected. DHS notes that it'll consider including community service and actively seeking work as qualified activities.

"As the federal comment period closes on the 15th and the negotiations with CMS progress, we look forward to working with our partners to implement this substantial entitlement reform and continue our success in eliminating the coverage gap in Wisconsin while helping our childless adult members transition from government dependence to independence," DHS spokeswoman Jennifer Miller wrote in an email.